Exchange of information and transparency in the BEPS Action Plan: An analysis of the legal issues

International cooperation between governments on fiscal affairs and administrative transparency has a key role in counteracting the phenomena of tax evasion and tax avoidance.

Corporate Taxes, CFCs, Double Taxation, Anti-Avoidance, Withholding Taxes

Thin capitalisation rules in Brazil and international tax principles: Part I

It is common for multinational enterprises around the world to finance their associated subsidiaries in high-level tax jurisdictions through issuing debts rather than equities.

Anti-Avoidance, ROW

Thin capitalisation rules in Brazil and international tax principles: Part II

In Part I, Gabriel Magalhães Borges Prata examined Brazil’s thin capitalisation regime. He concludes this discussion here.

Anti-Avoidance, ROW

The impact of BEPS on German transfer pricing practice – practical issues and problems

The ever growing number of transactions involving MNEs over the past decade has resulted in transfer pricing becoming increasingly important.

Double Taxation, Anti-Avoidance

Russia’s ‘deoffshorisation’ rules on controlled foreign companies move closer to implementation

The Russian government has joined the ranks of a great number of other jurisdictions which are seeking to introduce mandatory reporting requirements on the unreported capital of its citizens, placed, until now, in offshore locations.

Corporate Taxes, CFCs, ROW

Cyprus: A tax efficient IP box

This article provides analysis of the treatment of income from intellectual property within Cyprus’ corporate tax regime.

Corporate Taxes, Double Taxation

Is cloud computing a challenge to the traditional concept of a permanent establishment?

The term cloud is used by the information and communication technologies (ICT) industry to indicate, primarily, virtual platforms or infrastructures that allow the execution of codes (services, applications, among others) in various forms across multiple resources, with relevant data.

Region, Europe

BRICS and article 12: international tax policy implications: Part 4

In this final part, Peter Wilson concludes his discussion of Article 12. Parts 1-3 appeared in the previous three issues of ITR.

Double Taxation, ROW
Corporate Taxes

The Turkish corporate tax regime – An international perspective: Part III

In Part III, Okan Netek concludes his commentary on the Turkish corporate tax system related to international taxation.

Corporate Taxes
Anti-Avoidance

The Bulgari tax case

The following commentary details the investigation into perceived tax evasion by the Italian jeweller, Bulgari, in the context of the wider work of the Italian tax authorities and global anti-avoidance policies.

Anti-Avoidance, Europe
Region

The concept of beneficial ownership in the OECD model tax convention 2014: A critical analysis – Part I

Tax avoidance and tax evasion schemes undermine the foundations of wealth of developed and developing countries.

Double Taxation, Europe
Double Taxation

The Turkish corporate tax regime – An international perspective: Part II

In Part I, Okan Netek introduced the Turkish corporate tax system related to international taxation. This discussion continues here in Part II.

Double Taxation, Transfer Pricing
Investment and Indirect Taxes

Investment in Colombia from an international taxation perspective: Part 2

In Part I, Sylvia H. Torres Caro discussed how Colombia attracts foreign investment and focused her discussion on legal stability agreements put in place by Colombia and other Latin American countries. She concluded by briefly discussing the role played by Colombia’s double tax treaties in securing foreign direct investment. Part II continues this discussion.

Investment and Indirect Taxes, US/Americas
Practice

Is cloud computing a challenge to the traditional concept of a permanent establishment?

Part 3

In Parts 1 and 2, which appeared in the March and April issues, Maria Cecilia Rossi discussed Cloud Computing and its interaction with the concept of permanent establishment. Here, in Part 3, she concludes her discussion.

Corporate Taxes, Practice